very quick introduction for those of you who don’t know me. I’ve been with Heywood for over 23 years. Most recently I’ve been working on i-Connect, our data exchange solution for the public sector, implementing the product at 54 customer sites over the last eight years and helping to develop our award winning software.
I started working full time on the Pensions Dashboards Programme workstream in January 2022. I’m delighted to have been given the opportunity to be involved in this fascinating and fast-moving project. I’m looking forward to the day when the first dashboard is officially launched, and we can finally view our separate pension pots and state pension values in one place.
The Department for Work and Pensions published an indicative draft of The Pensions Dashboards Regulations 2022 for consultation by the industry on 31 January 2022. A modest 28-page document, covering the following key areas:
Overview of Dashboards.
Data.
How will pensions dashboards operate? Find and View.
Connection: What will occupational pension schemes be required to do?
Staging – the sequencing of scheme connection.
Compliance and enforcement.
Qualifying pensions dashboard services.
In contrast, the accompanying Consultation on the draft Pensions Dashboards Regulations 2022, was an epic 135 pages, but an extremely useful reference tool for all interested parties who responded to the six-week consultation.
You can find both documents here, although you’ve missed the deadline if you were planning to respond, as this closed on 13 March 2022!
Staging dates
The draft regulations outlined the latest staging dates for all Defined Benefit and Money Purchase Schemes with 100 or more active and deferred members. This is the date when you’re statutorily obliged to connect to the Pensions Dashboards Programme’s ecosystem. For our corporate DB customers this will begin from 30 November 2023. For our Public Service customers the staging date has been pushed back to 30 April 2024, due to the ongoing McCloud remedy.
Staging dates update:
Currently, there are no fixed staging dates set.
The final connection deadline for all schemes is 31 October 2026. However, the government will issue guidance outlining phased connection dates based on size and type of scheme.
Engagement on this proposed staging timetable is expected to begin in autumn 2024. Once finalised, schemes will receive at least six months' notice of their individual connection date.
The draft regulations specified response times for the return of administrative, signpost (additional information about the pension scheme) and value data:
|
Data Type |
Response time (following receipt of view request) |
|
Administrative data |
Immediate |
|
Signpost data |
Immediate |
|
Value data |
10 Days* |
*Value data is expected to be taken from annual benefit illustrations if the calculation date is no greater than 12 months from the current date. If the value data is unavailable/out of date, the scheme will have up to 10 days to make this available.
The response times are challenging, but we’re confident our Integrated Service Provider solution will deliver all view data to the dashboards in the timescales defined in the draft regulations.
TPR fines!
TPR have the option to issue penalties of up to £5,000 to individuals and up to £50,000 in other cases, for any instance of non-compliance with the Regulations (chapter 28, part 3 if you’re interested!).
The Pensions Dashboards Programme provided updated draft versions of their standards on the 31 January 2022 to support the consultation process. These included:
Data standards usage guide.
Design standards scope.
Reporting standards scope.
Technical standards.
A guide to the code of connection – which will include security, service, and operational standards.
All of these documents can be found here.
The Data Usage Guide is a revised version of the Data Standards Guide that was published in December 2020 and provides details of all the find data being sent from the identity service and the view data which is required to be returned to the dashboards.
Have any significant changes been made?
Find data:
A new ‘No NINO’ element has been added to support individuals with UK pensions who may not have a NI number. For example, overseas members.
View data:
A ‘Details unavailable’ element has been added to inform the dashboard user that a partial match has been made or to prompt the user to contact the scheme administrator directly before providing information online. For example, where there is suspected fraud, benefit reconstruction, significant errors, or another reason that data is unavailable online.
A ‘Date of birth’ element has been added to the administrative data, to allow qualifying dashboard providers to translate any of the ‘date’ items passed to them into an 'age’ for display purposes. Date of birth is already a find data element; however, the security model of the PDPs central data architecture means that the dashboard cannot get this information from the identity service.
New elements have been added to inform dashboard users if the values displayed include survivors’ benefits (fixed value of ‘Yes’), or whether the value quoted is single-life only.
Warning elements have been added to provide users with important additional information to understand before making any decisions. The values are currently fixed; however, the PDP will review the fixed values during alpha and beta testing.
New elements have been added to provide messages to users in the event value data cannot be displayed.
Heywood Pension Technologies performed a detailed review of the draft regulations, the consultation document and the PDP data standards, and submitted a consultation response to the DWP on 10 March 2022. The response was shared in full with all customers on 3 March 2022.
DWP are expected to complete their review following the consultation around July and the Pensions Dashboards Regulations 2022 will be laid before parliament in Autumn. MaPS will have the authority to set/maintain standards themselves following parliamentary approval of the regulations.
Heywood Pensions Technologies have participated in all PDP Alpha Participant workshop events and attended the DWP draft regulation consultation webinars.
Our dedicated Pensions Dashboards Programme Development Team are building our Integrated Service Provider prototype and beginning to integrate with the PDPs Application Program Interfaces (the technology used to interact with the PDPs Central Digital Architecture).
We’ve also been engaging regularly with customer across our client base, and with other interested partners, to share Pensions Dashboards Programme knowledge and help shape our Integrated Service Provider development.
Customers should look out for the Pensions Dashboards Programme webinars we’re hosting throughout March and April - they are a great way to get up to speed and give you the opportunity to ask us any dashboards-related questions.